Dr. George Domfe, Founding President of APL
A policy think tank, Africa Policy Lens (APL), has formally requested detailed disclosures from the Bank of Ghana regarding the divestment of a portion of the country’s gold reserves during the final quarter of 2025.
The request, submitted under the Right to Information Act, 2019 (Act 989), seeks to compel the central bank to release comprehensive information about the transactions amid growing public debate over the management of Ghana’s gold reserves.
In a letter addressed to the Governor of the Bank of Ghana, Dr. Hayford Mensah Ayerakwa, Director of Research, Administration and Partnerships at Africa Policy Lens, described the matter as one of “significant national interest.” He noted that gold remained a critical component of Ghana’s monetary stability and international reserve management.
According to Dr. Ayerakwa, the request is particularly important at a time when global gold prices have been rising sharply and central banks across the world are increasing their gold holdings as a hedge against economic uncertainty.
He argued that any large-scale divestment of a strategic national asset such as gold must be accompanied by a high level of transparency and public accountability.
Detailed information requested
In the letter, Africa Policy Lens is asking the Bank of Ghana to disclose 20 categories of information relating to the transactions executed during the third and fourth quarters of 2025.
Among the details requested is confirmation of the total quantity of gold divested, including the precise weight in tonnes and ounces, as well as the specific dates on which the transactions were executed.
The think tank is also seeking information on the pricing framework used to value the gold, including the reference price from the London Bullion Market Association (LBMA) or any other benchmark applied in determining the sale price.
APL has further asked the central bank to disclose the average realised sale price per ounce and the identities of the counterparties or purchasing entities involved in the transactions, including their beneficial ownership structures.
The organisation is also requesting clarification on whether any local partners participated in the transactions and, if so, the ownership structures of such entities.
Structure and proceeds of the transactions
Beyond the identities of buyers, the policy group is demanding details on the structure of the transactions themselves.
Specifically, it wants the central bank to explain whether the gold was sold outright or transferred through other arrangements such as swaps, leases or structured financial agreements. It also seeks clarification on whether the deals involved any buy-back clauses.
The letter further asks for information on the custodial chain and delivery process, including whether the divested gold was physically shipped out of Ghana and the dates of such shipments.
APL is also requesting disclosure of the total proceeds realised from the transactions, the currencies in which the payments were received and the accounts or financial instruments into which the funds were credited.
In addition, the think tank wants the central bank to explain how the proceeds were subsequently used, including whether they were allocated to reserve management operations, debt servicing or investment activities.
Advisors and transaction costs
The request extends to the role of financial intermediaries in the transactions.
APL is asking the central bank to identify any financial advisers, consultants, bullion banks, brokers or transaction advisers that facilitated the deals.
The organisation is also seeking full disclosure of any commissions, fees or compensation paid in relation to the transactions, including the identities of the recipients and the amounts involved.
Decision-making process
The think tank is further seeking clarification on the policy rationale behind the timing of the gold divestment.
It has requested details of the market analysis, indicators or projections that informed the decision to sell, including whether the central bank conducted strategic market timing assessments before executing the transactions at a time when global projections indicated a possible rise in gold prices towards $5,000 per ounce.
APL is also asking the central bank to identify the decision-making authority responsible for approving the divestment.
Specifically, it wants confirmation of whether the decision received approval from the Bank’s Board and the date on which such approval was granted.
The organisation is additionally seeking clarification on whether the decision involved the Cabinet, the Ministry of Finance or any other government authority.
Questions on parliamentary oversight
Among the final issues raised in the request is whether Parliament was informed about the decision to divest part of Ghana’s gold reserves.
APL is also seeking clarification on why the central bank reportedly moved to rebuild its gold reserves shortly after the divestment exercise.
The think tank further asked the Bank of Ghana to explain the accountability framework surrounding the transactions, including who would be held responsible should any financial losses to the country be established.
Call for transparency
Dr. Hayford Mensah Ayerakwa emphasised that the information requested was intended to promote transparency, and restore public confidence in the management of Ghana’s strategic financial assets.
“The people of Ghana deserve full clarity on the strategic decisions involving our national gold reserves,” the letter stated.
He added that timely disclosure would help address inconsistencies in the ongoing public discourse about the management of the country’s gold reserves.
Under the Right to Information Act, 2019 (Act 989), public institutions are required to respond to such requests within specified statutory timelines.
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